Notwithstanding section
72, in determining the extent to which a distribution is a qualified charitable distribution, the entire amount of the distribution shall be treated as includible in gross income without regard to subparagraph (A) to the extent that such amount does not exceed the aggregate amount which would have been so includible if all amounts in all individual retirement plans of the individual were distributed during such taxable year and all such plans were treated as 1 contract for purposes of determining under section
72 the aggregate amount which would have been so includible. Proper adjustments shall be made in applying section
72 to other distributions in such taxable year and subsequent taxable years.